AVRORA COMPANY GROUP
PERSONAL DATA
PROCESSING POLICY

General Provisions

This personal data processing policy is compiled in accordance with the requirements of the Federal Law of 27.07.2006 No. 152-FZ "On Personal Data" (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by GK Aurora (hereinafter referred to as the Operator).

1.1. The Operator sets as its most important goal and condition for its activities the observance of human and civil rights and freedoms in the processing of their personal data, including the protection of the right to privacy, personal and family secrets.

1.2. This Operator's policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the website https://gk-avrora.ru/.

Basic concepts used in the Policy

2.1. Automated processing of personal data — processing of personal data using computer technology.

2.2. Blocking of personal data — temporary termination of the processing of personal data (except in cases where processing is necessary to clarify personal data).

2.3. Website — a set of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the internet at the network address https://gk-avrora.ru/.

2.4. Information system of personal data — a set of personal data contained in databases and information technologies and technical means ensuring their processing.

2.5. Depersonalization of personal data — actions resulting in the impossibility of determining, without the use of additional information, the belonging of personal data to a specific User or other subject of personal data.

2.6. Processing of personal data — any action (operation) or set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.7. Operator — a state body, municipal body, legal or physical person, independently or jointly with other persons, organizing and/or carrying out the processing of personal data, as well as determining the purposes of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data.

2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website https://gk-avrora.ru/.

2.9. Personal data allowed by the subject of personal data for distribution — personal data to which the subject of personal data has given consent for processing and to which an unlimited number of persons has access, in the manner prescribed by the Personal Data Law (hereinafter referred to as personal data allowed for distribution).

2.10. User — any visitor to the website https://gk-avrora.ru/.

2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific circle of persons.

2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarizing an unlimited circle of persons with personal data, including the publication of personal data in the media, placement in information and telecommunication networks, or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to the authority of a foreign state, a foreign individual, or a foreign legal entity.

2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data with the impossibility of further restoration of personal data content in the personal data information system and/or the destruction of physical carriers of personal data.

Main rights and obligations of the Operator

3.1. The Operator has the right to:

— receive reliable information and/or documents containing personal data from the subject of personal data;

— continue processing personal data without the consent of the subject of personal data in case of withdrawal of consent by the subject of personal data for processing personal data, as well as in the case of sending a request for the termination of personal data processing, provided there are grounds specified in the Personal Data Law;

— independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

— provide the subject of personal data with information regarding the processing of their personal data upon their request;

— organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;

— respond to requests and inquiries from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;

— notify the authorized body for the protection of the rights of subjects of personal data of the necessary information within 10 days from the date of receipt of such a request;

— publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;

— take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions concerning personal data;

— terminate the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;

— perform other duties provided for by the Personal Data Law.

Main rights and obligations of subjects of personal data

4.1. Subjects of personal data have the right to:

— receive information regarding the processing of their personal data, except in cases provided by federal laws. The information is provided to the subject of personal data by the Operator in an accessible form and should not contain personal data relating to other subjects of personal data, except when there are legal grounds for disclosing such personal data. The list of information and the procedure for its receipt are established by the Personal Data Law;

— demand the operator to clarify their personal data, block or destroy it in case the personal data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the declared purpose of processing, as well as take measures provided by law to protect their rights;

— set the condition of prior consent when processing personal data for the promotion of goods, works, and services in the market;

— withdraw consent to the processing of personal data, as well as send a request to terminate the processing of personal data;

— appeal to the authorized body for the protection of the rights of subjects of personal data or in court against unlawful actions or inaction of the Operator in the processing of their personal data;

— exercise other rights provided by the legislation of the Russian Federation.

4.2. Subjects of personal data are obliged to:

— provide the Operator with reliable data about themselves;

— notify the Operator about the clarification (updating, changing) of their personal data.

4.3. Persons who have provided the Operator with false information about themselves or information about another subject of personal data without the consent of the latter are liable in accordance with the legislation of the Russian Federation.

Principles of personal data processing

5.1. The processing of personal data is carried out on a lawful and fair basis.

5.2. The processing of personal data is limited to achieving specific, predetermined, and legitimate goals.

The processing of personal data incompatible with the purposes of collecting personal data is not allowed.

5.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes incompatible with each other.

5.4. Only personal data that meets the purposes of its processing is subject to processing.

5.5. The content and volume of personal data being processed correspond to the stated purposes of processing. The redundancy of personal data being processed concerning the stated purposes of its processing is not allowed.

5.6. The accuracy of personal data, its sufficiency, and, in necessary cases, relevance concerning the purposes of processing personal data is ensured during the processing of personal data. The Operator takes the necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.

5.7. The storage of personal data is carried out in a form that allows determining the subject of personal data, no longer than required by the purposes of personal data processing, if the period for storing personal data is not established by federal law, an agreement, or the subject of personal data is a party, beneficiary, or guarantor in the execution of the agreement. The processed personal data is destroyed or depersonalized upon achieving the processing goals or in case of loss of the need to achieve these goals unless otherwise provided by federal law.

Purposes of personal data processing

6.1. The purpose of processing the personal data of the User is to inform the User by sending emails; providing the User with access to services, information, and/or materials contained on the website.

6.2. The Operator also has the right to send notifications to the User about new products and services, special offers, and various events. The User can always refuse to receive informational messages by sending an email to the Operator at info@gk-avrora.ru with the note "Refusal of notifications about new products and services and special offers".

6.3. Depersonalized data of Users collected through internet statistics services is used to collect information about Users' actions on the site, improve the quality of the site, and its content.

Legal basis for the processing of personal data

7.1. The legal basis for the processing of personal data by the Operator is:

— federal laws, other regulatory legal acts in the field of personal data protection;

— the User's consent to the processing of their personal data, to the processing of personal data allowed for distribution.

7.2. The Operator processes the User's personal data only if it is filled out and/or sent by the User independently through special forms located on the website https://gk-avrora.ru/ or sent to the Operator via email. By filling out the appropriate forms and/or sending their personal data to the Operator, the User agrees to this Policy.

7.3. The Operator processes depersonalized data about the User if it is allowed in the User's browser settings (the storage of cookies and the use of JavaScript technology is enabled).

7.4. The subject of personal data independently decides on the provision of their personal data and gives consent freely, by their own will and in their interest.

Conditions for the processing of personal data

8.1. The processing of personal data is carried out with the consent of the subject of personal data for the processing of their personal data.

8.2. The processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or by law, to perform and fulfill the functions, powers, and duties imposed by the legislation of the Russian Federation on the Operator.

8.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body, or an official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.

8.4. The processing of personal data is necessary for the execution of an agreement to which the subject of personal data is a party or beneficiary or guarantor, as well as for the conclusion of an agreement on the initiative of the subject of personal data or an agreement under which the subject of personal data will be a beneficiary or guarantor.

8.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the Operator or third parties or to achieve socially significant goals, provided that this does not violate the rights and freedoms of the subject of personal data.

8.6. The processing of personal data to which access by an unlimited number of persons is granted by the subject of personal data or at their request (hereinafter referred to as publicly available personal data) is allowed.

8.7. The processing of personal data subject to publication or mandatory disclosure under federal law is carried out.

Procedure for collecting, storing, transferring, and other types of personal data processing

The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.

9.1. The Operator ensures the security of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.

9.2. The personal data of the User will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party for the fulfillment of obligations under a civil law contract.

9.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator's email address info@gk-avrora.ru marked "Updating personal data".

9.4. The term for processing personal data is determined by achieving the purposes for which the personal data was collected unless a different period is provided by the contract or current legislation. The User can withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email to the Operator's email address info@gk-avrora.ru marked "Withdrawal of consent to the processing of personal data".

9.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these third parties (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or the User is obliged to familiarize themselves with these documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.

9.6. The prohibitions established by the subject of personal data on the transfer (excluding granting access), as well as on processing or processing conditions (excluding obtaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in state, public, and other public interests defined by the legislation of the Russian Federation.

9.7. The Operator ensures the confidentiality of personal data when processing personal data.

9.8. The Operator stores personal data in a form that allows determining the subject of personal data no longer than required by the purposes of processing personal data, if the period for storing personal data is not established by federal law, an agreement to which the subject of personal data is a party, beneficiary, or guarantor.

9.9. A condition for terminating the processing of personal data may be the achievement of the personal data processing goals, the expiration of the consent of the subject of personal data, or the withdrawal of consent by the subject of personal data, as well as the identification of unlawful processing of personal data.

List of actions performed by the Operator with the received personal data

10.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distribution, provision, access), depersonalizes, blocks, deletes, and destroys personal data.

10.2. The Operator carries out the automated processing of personal data with the receipt and/or transmission of the received information via information and telecommunication networks or without it.

Cross-border transfer of personal data

11.1. Before starting the cross-border transfer of personal data, the Operator must ensure that the foreign state to whose territory the transfer of personal data is supposed to be carried out provides reliable protection of the rights of subjects of personal data.

11.2. Cross-border transfer of personal data to the territory of foreign states that do not meet the above requirements can be carried out only if there is written consent from the subject of personal data to the cross-border transfer of their personal data and/or the execution of an agreement to which the subject of personal data is a party.

Confidentiality of personal data

The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.

Final provisions

13.1. The User can receive any clarifications on questions of interest regarding the processing of their personal data by contacting the Operator via email at info@gk-avrora.ru.

13.2. This document will reflect any changes in the personal data processing policy by the Operator. The policy is valid indefinitely until replaced by a new version.

13.3. The current version of the Policy is freely available on the internet at https://gk-avrora.ru/